This post is a rejoinder to my "Public Participation in Strategy-making" published on 24 January 2013. It exposed serious flaws in the efforts of the Northern Ireland Government's lead Department, the Office of First and Deputy First Ministers (OFMDFM), and also that of the Department for Social Development (DSD) to draft strategy.
That January post, like this one, forms one part of my blog series entitled "Northern Ireland's Strategy Scandal."
My January post summarised the detailed comments I had submitted to OFMDFM and to DSD on their draft strategies published for public consultation.
In essence, I discovered that both draft strategies were defective in terms of content and were also dreadfully presented.
The OFMDFM's document purported to address the issue of community relations; the DSD's to address the related area of urban regeneration and community development.
This new post discusses some issues arising from the DSD's attempt to finalise its strategy which has been published on 2 July 2013.
Representation
My representation to DSD in October 2012 had excoriated its draft strategy as deficient in content. I provided a paragraph by paragraph critique to prove the point beyond any doubt.
The submission added that the consultation report's message was lost because of the document’s prolixity, bad presentation, and failure to articulate a coherent message.
It argued that DSD ignored the OFMDFM’s red book on policy-making.
I suggested that the draft strategy comes across as having been composed as a mechanistic exercise, lacking creative thought and bereft of innovation, never mind radical purpose.
My critique provided examples from the draft document to prove each of my points.
My representation argued that DSD cannot justify describing the document as a policy framework. Neither can it even be described as a strategy because it concentrates on process and sets out no vision.
I pointed out that it proposes no explicit new direction or rationale for a change of policy.
In 22 pages, all that the DSD's draft offers is a vague promise to assess existing policies and to develop new ones.
The DSD could do better, I suggested.
Questions
My representation last October closed by asking DSD to respond to my submission
point by point and answer the following questions.
- Who composed the “Urban Regeneration and Community Development Framework 2012?”
- Was it written by a nominated official or was it a collaborative production by a number of people within the DSD?
- What are the qualifications and expertise of the document’s author or authors? Was she, he, or were they, for example, sociologists, town planners, economists, community development professionals, administrative civil servants, or does the authorship have some other set of qualifications and skills? If so, what are they?
- Why is the document published anonymously with no reference to the staff who may have been involved in its composition?
- Who had the final say, like an editor in chief, of the document that was eventually finalised for publication?
- Was the document written by a private consultant or by some other advisor to DSD? If so, what were the qualifications and skills of that person or team?
- It is an odd omission that the date of the document’s publication appears neither on the cover nor on the opening or closing pages of text. What is the reason for publishing a policy framework without a publication date?
- On what background advice, reports, statistical data, or other evidence, is the report based?
- Why is the term “Policy Framework” used rather than, say, Policy, Strategy, Guidelines, or Action Plan?
- Apart from publishing the document and its mailing to selected bodies, what other attempts are being made by DSD to promote participation with members of the public?
- What weight will be afforded to public comments received to the DSD’s consultation document; and how exactly are they going to be taken into account?
- At what staffing level will this representation be read and considered?
I posed these questions for two reasons.
The first was to seek important information, absent from the document, and which might provide more robust explanation of the qualitative and quantative purposes and methodology of the DSD in drafting its strategy.
My thinking is that the best policy, or solution to a problem, is achieved through a process of thesis, anthithesis, and synthesis. Cross-examination and debate can help refine, alter and improve or change policy elements.
My other reason was to set the DSD a test to ascertain how seriously and at what level representations are considered. A failure to respond would imply that my full submission might not have been read; and if questions can be ignored, then so too might be my point-by-point critique.
In the absence of a response after almost eight months, I decided to contact the Permanent Secretary, the Department's head civil servant.
Recent correspondenceThe first was to seek important information, absent from the document, and which might provide more robust explanation of the qualitative and quantative purposes and methodology of the DSD in drafting its strategy.
My thinking is that the best policy, or solution to a problem, is achieved through a process of thesis, anthithesis, and synthesis. Cross-examination and debate can help refine, alter and improve or change policy elements.
My other reason was to set the DSD a test to ascertain how seriously and at what level representations are considered. A failure to respond would imply that my full submission might not have been read; and if questions can be ignored, then so too might be my point-by-point critique.
In the absence of a response after almost eight months, I decided to contact the Permanent Secretary, the Department's head civil servant.
On 4 June 2013, I wrote and posted a letter to the DSD's Permanent Secretary.
I referred him to my detailed response of October to his 22-page public consultation document “Urban Regeneration and Community Development Framework 2012.”
My 8-page representation had included constructive comments as well as
questions within the text. That analysis together with its series of closing questions matter, and all
of which I had expected to be answered.
Apart from an acknowledgement emailed
to me on 23 October by an unnamed person in the urban policy review branch, I had received no communication about the strategy from
DSD in the intervening period of over seven months.
I opined in my letter that because public representation in public
policy-making is an important part of the democratic process, it behoves policy
makers and advisors to reciprocate.
This, I suggested, has the additional benefit of ensuring that citizens’ comments are heard and shown to be taken into account before policy is finalised.
This, I suggested, has the additional benefit of ensuring that citizens’ comments are heard and shown to be taken into account before policy is finalised.
I invited the Permanent Secretary, as politely as I could, to provide me with a reply to the questions posed in my representation.
Four weeks later, on 2 July 2013 I received a reply signed by the Permanent Secretary himself. On the same day, I acknowledged receipt of his letter via email to his personal assistant.
I did so promptly as a courtesy and also because his reply had emphasised that
"we do not normally respond to individuals. We do not have the resources."
I am honoured and grateful, therefore, to receive exceptional consideration.
I am also flattered by his closing comment thanking me for coming back to him, that my argument has been taken seriously, and that my interest is welcomed.
Coincidentally, on the same day (and less than an hour after I received the Permanent Secretary's letter), I also received a notification by email from the DSD Urban Policy Branch advising me that the final strategy was now being published that day.
The message added that :-
Four weeks later, on 2 July 2013 I received a reply signed by the Permanent Secretary himself. On the same day, I acknowledged receipt of his letter via email to his personal assistant.
I did so promptly as a courtesy and also because his reply had emphasised that
"we do not normally respond to individuals. We do not have the resources."
I am honoured and grateful, therefore, to receive exceptional consideration.
I am also flattered by his closing comment thanking me for coming back to him, that my argument has been taken seriously, and that my interest is welcomed.
Coincidentally, on the same day (and less than an hour after I received the Permanent Secretary's letter), I also received a notification by email from the DSD Urban Policy Branch advising me that the final strategy was now being published that day.
The message added that :-
"The Framework can be viewed at"
Crucially, he adds that
"the drafting of the consultation document was taken forward by DSD officials."
Consideration of reply
If the draft strategy was indeed as thoroughly informed with expertise and evidence as the Permanent Secretary says, I am now at an even greater loss to comprehend how the DSD officials managed to produce such an abysmal document for consultation with the public.
How the Permanent Secretary and the Minister authorised its publication, given the flaws which I highlighted in my submission, remains a mystery.
I am disappointed that DSD refuses to engage with individuals because of an alleged paucity of resources.
The draft strategy in question provoked a mere 72 responses, a very low return.
I have, therefore, to take issue with the Permanent Secretary's description of the responses as "a significant number."
It is 4 times less that the OFMDFM received for its draft community relations strategy. That number was itself (288 replies) very small compared to the much higher numbers who responded to consultation documents by other Departments in recent years.
A striking and paradoxical feature is that of all Departments which comprise the administration in Northern Ireland, DSD should be the most proficient at consultation.
It, after all, is tasked with engaging with communities, something that is central to its mission, developing policies and action plans for community development and regeneration "from the bottom up."
Its officials could reasonably be expected, therefore, to have substantial experience and skill in the role of community engagement. If that ability were to be measured against the community's responsiveness to its key consultation document on community development and regeneration, the resultant score must have (at least privately) disappointed the top officials in the DSD - whatever the line the Permanent Secretary takes with people like me.
Moreover, I suspect that not all of the 72 respondents asked questions requiring a response. In which case, the scale of task in having to respond to individuals will be even less.
To illustrate the contrast in attitude, when OFMDFM failed to pick up on the questions raised in my representation to the community relations strategy, its Permanent Secretary apologised for the oversight and addressed some of my questions when I brought the issue to his attention.
Refusal by DSD to answer questions and to respond to constructive debate defeats the purpose of the exercise of making public consultation meaningful. The Department's stance inexplicably passes up what it should recognise as the ideal opportunity presented by my questioning to rebut my argument and to justify its own policy.
The DSD's rationale for refusing to engage, therefore, appears disingenuous for the above reasons.
Conclusions
The sad thing is that even before I study the new and final strategy - which is not open for public comment - the initial impression is unfavourable, judging by the gibberish pseudo-jargon used by DSD in its announcement on 2 July. Prizes should be offered to any member of the public who can decipher the code. It says, transmogrifyingly:
"In addition to the policy objectives and supporting actions a key component of the Policy Framework is the decision to move operational activity both now and after the Reform of Local Government to an outcomes-focused approach which measures impact rather than activities funded or associated outputs."
I close with two observations.
The first is that the OFMDFM's Red Book on policy-making seems to have been consigned to gather dust on shelves if the language of the announcement and impressions gained from initial perusal of the DSD's final strategy are accurate.
The other and most critical point is that if officials cannot compose comprehensible and coherent policies on important matters, and if elected politicians willingly endorse badly drafted policy, it means that the community of Northern Ireland will not achieve the progress it craves because of the failure of those who are paid to serve the public interest.
Our citizens deserve better.
